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Morfin
06-26-2009, 09:22 AM
Justices Rule Lab Analysts Must Testify on Results

WASHINGTON — Crime laboratory reports may not be used against criminal defendants at trial unless the analysts responsible for creating them give testimony and subject themselves to cross-examination, the Supreme Court ruled Thursday in a 5-to-4 decision.

The ruling was an extension of a 2004 decision that breathed new life into the Sixth Amendment’s confrontation clause, which gives a criminal defendant the right “to be confronted with the witnesses against him.”

Four dissenting justices said that scientific evidence should be treated differently than, say, statements from witnesses to a crime. They warned that the decision would subject the nation’s criminal justice system to “a crushing burden” and that it means “guilty defendants will go free, on the most technical grounds.”

The two sides differed sharply about the practical consequences of requiring testimony from crime laboratory analysts. Justice Anthony M. Kennedy, writing for the four dissenters, said Philadelphia’s 18 drug analysts will now each be required to testify in more than 69 trials next year, and Cleveland’s six drug analysts in 117 trials each.

Noting that 500 employees of the Federal Bureau of Investigation laboratory in Quantico, Va., conduct more than a million scientific tests each year, Justice Kennedy wrote, “The court’s decision means that before any of those million tests reaches a jury, at least one of the laboratory’s analysts must board a plane, find his or her way to an unfamiliar courthouse and sit there waiting to read aloud notes made months ago.”

Justice Antonin Scalia, writing for the majority, scoffed at those “back-of-the-envelope calculations.” In any event, he added, the court is not entitled to ignore even an unwise constitutional command for reasons of convenience.

“The confrontation clause may make the prosecution of criminals more burdensome, but that is equally true of the right to trial by jury and the privilege against self-incrimination,” Justice Scalia wrote. “The sky will not fall after today’s decision,” he added.

But that is not how prosecutors saw it. “It’s a train wreck,” Scott Burns, the executive director of the National District Attorneys Association, said of the decision.

“To now require that criminalists in offices and labs that are already burdened and in states where budgets are already being cut back,” Mr. Burns said, “to travel to courtrooms and wait to say that cocaine is cocaine — we’re still kind of reeling from this decision.”

Mr. Burns said complying with the ruling would be particularly tough in large rural states with a single crime laboratory and in old cases where the analyst has died or moved away.

The decision came in the wake of a wave of scandals at crime laboratories that included hundreds of tainted cases in Michigan, Texas and West Virginia. William C. Thompson, a professor of criminology at the University of California, Irvine, said those scandals proved that live testimony from analysts was needed to explore potential shortcomings in laboratory reports.Link (http://www.nytimes.com/2009/06/26/us/26lab.html?_r=1&hp)

I have yet to read this opinion, but two things come to mind:

First, I agree with this decision, based on the background in the Times article.

Second, it is interesting that the 5 conservative justices decided this case in favor of defendants' rights, while the liberals came down on the prosecution's side, favoring convenience over defendant rights.

Insomniac
06-26-2009, 09:43 AM
Don't police officers have to testify at trials? I don't see how this is much different in principle, especially as far as inconvenience.

Morfin
06-26-2009, 09:55 AM
Yes, that the is the 6th Amendment right to confront your accusers and that is the basis for the decision. I will try to read it later today, but I suspect that the minority felt that these were administrative workers doing a rote function and therefore, not technically fact witnesses.

redsox39
06-26-2009, 10:20 AM
In related news, CSI just merged with Boston Legal...

Stax
06-26-2009, 10:26 AM
Don't police officers have to testify at trials? I don't see how this is much different in principle, especially as far as inconvenience.

The difference, at least as I see it, is cops are working the case fulltime, that's their job. The lab tech is testing and running things for multiple cases at once, but now they'll have to have "court days" or something I guess where they stop doing lab work and just go to court and pound out their testimonies.

Hanover Fist
06-26-2009, 10:31 AM
I can see the merits in both sides of this issue, I'm not sure where I stand on if this is good or bad. Tough call for me.

Stax
06-26-2009, 10:34 AM
I can see the merits in both sides of this issue, I'm not sure where I stand on if this is good or bad. Tough call for me.

Exactly. My big issue is while I understand the Court wants to make a bright-line rule, this just seems like a bad place for one as sometimes it's fitting and sometimes it isn't. To use the example from the article, it's stupid to require a live person to come out just to say "Yes, my tests confirmed it was cocaine" when you have the lab report right there. For more complex stuff, though, it makes sense.

hatepoppy
06-26-2009, 11:40 AM
Don't police officers have to testify at trials? I don't see how this is much different in principle, especially as far as inconvenience.

consider kennedy's statements regarding the burden on the analysts - cleveland has 117 drug cases/yr, eight drug analysts, and at least dozens of arresting officers in these cases. so each individual cop might see a few of these cases/yr, where the analysts are seeing 15/yr. plus, this is an expansion of teh existing analyst workload, as opposed to the status quo for cops.

hatepoppy
06-26-2009, 11:42 AM
Yes, that the is the 6th Amendment right to confront your accusers and that is the basis for the decision. I will try to read it later today, but I suspect that the minority felt that these were administrative workers doing a rote function and therefore, not technically fact witnesses.
if they were just monkeys pushing buttons this wouldnt even be a question. theyve got to be using ppl that know what they are talking about. specifically, those that have enough expertise to testify under oath that their results are accurate. kindof like how not every project engineer is liable, as only the primary engineer stamped the drawings.

Morfin
06-26-2009, 02:16 PM
I have read the decision and it is as straight-forward the Times story portrays. Scalia’s opinion is that the 6th Amendment provides an accused the right to confront and cross-examine his accusers. This means that any witness providing testimony must do it where the defendant has the ability to cross-examine the witness.

In this case, the Massachusetts statute provided that lab personnel could prepare a sworn “certificate” which stated the composition and amount of the tested sample to provide “prima facie” evidence. This, the majority concluded, was an affidavit, which provided factual testimony significant to the charge – the sample was cocaine and how much there was – because “distribution” charges depend on the amount the defendant was distributing. Scalia and the majority opined that this certificate presented evidence regarding an element of the charged crime and, since these were testimonial witnesses, the defendant has a 6th Amendment right to have those witnesses testify live at trial.

The majority, in a footnote, distinguished this testimony with that of persons who merely handled evidence as part of the chain of custody. The majority reasoned that there were merely administrative persons and therefore, they do not have to testify.

The dissent, authored by Justice Kennedy, put forward a number of arguments, some of which had a basis in hearsay exceptions to the rules of evidence. Part of the argument is not so much with the decision per se, but with the lack of guidance. For example, up to four people may handle a sample or be involved with the machine, such as the lab director regarding policies and maintenance and the person who did the calibration: there is no guidance whether all of those need to testify or just the one actually doing the testing, especially since each may have had the “power to introduce error.”

Maybe it is just because I disagree with Kennedy’s position, but the tone of his writing seems shrill and hyperbolic. He argues about “possible” ways that the majority’s opinion could be interpreted.

The one argument of Kennedy’s that gave me pause is that the cocaine was available for the defendant to test by an expert of his own choosing. This would then be able to be presented to show that the prosecution’s testing was flawed. While this argument does have some merit, IMO, it seems to come close to shifting the burden of proof to the defendant, which is obviously unconstitutional.

The clear rule is that the defendant has a right to confront all witnesses presenting testimony or evidence.

Stax
06-26-2009, 02:23 PM
But there is no cross-examining to be done on simpler matters of fact. If a technician runs a test on something and finds that yes, it is cocaine, and then puts it on a scale to tell you how much it is, what cross examining is there to be done?

Hanover Fist
06-26-2009, 02:42 PM
2 things this might lead to. 1, fewer people wanting to go into this line of work because of the fear of having to testify 2. Enormous cost increases to city and county budgets that will now have to hire more technicians to cover the work missed from court appearances.

Morfin
06-26-2009, 03:02 PM
But there is no cross-examining to be done on simpler matters of fact. If a technician runs a test on something and finds that yes, it is cocaine, and then puts it on a scale to tell you how much it is, what cross examining is there to be done?

How he ran the test, number of vials, when was the machine last calibrated, what test was run immediately before, who enters in the sample number and id, etc. This is no different than cross-examining the person who does the breathalyzer in a DUI trial.

The implication from your question is valid: What are the odds that someone will be able to show a problem or discrepancy? Probably very small, just like with the breathalyzer.

Note the Times article discussed the recent problems with some labs -- including Detroit's. Cross-examining a tech could show sloppy procedures or overwork that can lead to confusion and mistakes. Where the charge is cocaine possession, the #1 fact is whether the material is cocaine. Any defense attorney will attack there. Remember, all you need is a "reasonable doubt."

Morfin
06-26-2009, 03:04 PM
2 things this might lead to. 1, fewer people wanting to go into this line of work because of the fear of having to testify 2. Enormous cost increases to city and county budgets that will now have to hire more technicians to cover the work missed from court appearances.

Boy, talk about looking at the glass as being half empty. I look at it that it would be a great time to train and apply for a crime lab job. They're going to be hiring big time.

heelsguy
06-26-2009, 04:39 PM
Link (http://www.nytimes.com/2009/06/26/us/26lab.html?_r=1&hp)

I have yet to read this opinion, but two things come to mind:

First, I agree with this decision, based on the background in the Times article.

Second, it is interesting that the 5 conservative justices decided this case in favor of defendants' rights, while the liberals came down on the prosecution's side, favoring convenience over defendant rights.

there we go again classifying our justices based on the party of the president who appointed him/her.

that's what happens when you have the job for life: you are more likely to make the wise decision rather than the political one.

Morfin
06-26-2009, 05:07 PM
I'm not classifying them by party -- merely by how they are generally characterized. If they take a position that is different from their usual MO, then that is noteworthy. If and when Scalia ever takes a liberal stance in a decision, it will truly be noteworthy.

One more note to those Justice Thomas bashers. Note that the decision regarding the school search marked a rare occasion where he split with Scalia. Note in this case that Thomas wrote a concurring opinion, staking a different position than Scalia and the majority. Maybe, just maybe, we are beginning to see some independence by the silent justice.

Kerjack
06-26-2009, 05:13 PM
I wonder if they will be able to work around this a little, might the labs set up a 'testify room' where they can give a live video testimony over the web?

Hanover Fist
06-26-2009, 09:19 PM
Boy, talk about looking at the glass as being half empty. I look at it that it would be a great time to train and apply for a crime lab job. They're going to be hiring big time.

Somebody will have to pay for those extra crime lab jobs. Which means more tax dollars will be needed, or they use the same number of people and their available hours to do their jobs will decrease or quality will decrease. City/County money for crime lab personnel doesn't just magically appear enabling you to hire as many people as you want.